SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on the Made Available to Trade (MAT) submission by MarketAxess SEF Corporation (MarketAxess) for certain credit default swaps (Submission Swaps) pursuant the Commodity Exchange Act (CEA) and CFTC regulations.

SIFMA supports the contract-by-contract approach taken by MarketAxess with respect to the six factors set out in the MarketAxess submission. SIFMA also supports MarketAxess’s approach to showing how it meets the listing requirement by demonstrating how it supports the trading of the Submission Swaps. In addition, SIFMA requests that the Commission address the cross-border and packaged swap issues that will become even more important as a result of a MAT determination.